Responsibility and Cost Sharing. Who pays the Piper? And to the tune of what?

DEFRA announced on 7 July 2009 a joint industry and government working group to be chaired by the economist and government adviser, Rosemary Radcliffe. (See her notes on "ways of working" Sept 09) It is to advise on how best to develop a body to share responsibility and costs of animal disease with the livestock industry. There are concerns about the new board's powers and independence regarding policy. There are also other concerns relating to membership of the board, to staffing, to cost and to a number of other outstanding issues, such as animal welfare. The National Audit Office (pdf file) recently stated that

"the Department does not have sufficiently robust financial or performance information on controlling diseases to assess routinely the costs and benefits of intervention, and to underpin a transparent and equitable cost-sharing scheme.."

The new animal health body must accurately work out costs and they must be tightly controlled if livestock farming is to survive.

(Industry Cost Sharing a paper by Dr Roger Breeze.)"Ms Radcliffe was adamant responsibility sharing must come before cost sharing in her report. She wanted the group to take a good look at Defra's accounts - deemed unfit to consider full cost sharing in a 2010 National Audit Office report - before making any firm recommendations.
This process is now under way." FG Feb 24th 2012

LATEST

February 8th 2012 ~ "there must be concern about whether the mechanisms devised for responsibility and cost sharing will ever be able to make up for the imminent shortfall in funding." Veterinary Record

"As far as surveillance is concerned, the need for a solution is pressing, " says The Veterinary Record "the arrival of Schmallenberg virus is salutary and timely"
The AHVLA considers that the value of its surveillance programme in recent years has "greatly exceeded the cost" and estimates benefits at over 200 million pounds. But spending on the scanning surveillance programme is being cut from £10 million in 2009/10 to £6 million by 2014
Although very unwelcome, the arrival of Schmallenberg virus is, according to comment in the Vet Rec, "both salutary and timely" since arrangements for surveillance in England and Wales are under review. It is exactly

".. this kind of disease threat that might not be detected promptly if, for whatever reason, arrangements for surveillance fall short of the mark.
... robust networks are also needed nationally and internationally, with international cooperation playing a crucial role."

In particular, the Friedrich Loeffler Institute in Germany is praised for having made protocols and virus material available for use by other EU member states.
Ultimately, says the journal," the shape of surveillance in England and Wales will be determined by the outcome of the debate on partnership working and responsibility and cost sharing.... very often, you are trying to find something you don't know is there until you've looked for it....there must be concern about whether the mechanisms devised for responsibility and cost sharing will ever be able to make up for the imminent shortfall in funding."

January 31 2012 ~ It will require changes to the way everyone
works: Ministers; civil servants; animal keepers and their representative organisations; vets; other
stakeholders alike.

"....Unless
the right people join the Board, people whom the animal keepers and other stakeholders trust and
respect, it will not work. And the communication channels up and down to and from the Board have
to be excellent: if they are not, the initiative will fail. It will require changes to the way everyone
works: Ministers; civil servants; animal keepers and their representative organisations; vets; other
stakeholders alike. "

Last week, the NFU "criticised the lack of grassroots farm involvement and transparency in the body" (See FG) But Richard Davis, a dairy and arable farmer from North Bedfordshire, and Jonathan Rushton, an economist and senior lecturer at the Royal Veterinary College have now been co-opted and will attend their first meeting on February 7. There are now 7 non-executive members of the Board - which has already met formally 3 times.
The members of the Animal Health and Welfare Board for England (AHWBE)

September 16th 2011 ~ More than 60 people have applied for places on England's new Animal Health and Welfare Board (AHWBE).

"The AHWBE, which will be chaired by Michael Seals, the Derbyshire farmer who also chairs the National Fallen Stock Company, is being set up to give the industry a greater say in animal health policy.
The board will combine around eight experts from outside Government, including farmers, vets and animal welfare specialists, with DEFRA's chief veterinary officer and four other civil servants. External applicants applied as individual experts rather than representatives of trade bodies.
...
The make-up of the board is set to be finalised in October ..."

April 26th 2011 ~ Responsibility and Cost Sharing - the Animal Health and Welfare Board for England - operating within DEFRA itself - yet a "completely new way of working" says Jim Paice

Mr Paice is quoted on the DEFRA website today claiming that the new Board
".. replaces the old ways, where the people most affected by decisions were kept at arm's length from policymaking on those subjects." This may be wishful thinking. Gone are the plans for a non-departmental public body or arms-length body. The new Board will form part of the internal structure of DEFRA. Five senior DEFRA officials - including the chief veterinary officer - will be on the board, joined by "up to eight external members" including a chairman.
Board members who are "external" will be "required to have knowledge and experience of kept and farmed animals". Page 6 of the final Responsibility and Cost Sharing
for Animal Health and Welfare report in December issues a warning:

"....Unless
the right people join the Board, people whom the animal keepers and other stakeholders trust and
respect, it will not work. And the communication channels up and down to and from the Board have
to be excellent: if they are not, the initiative will fail. It will require changes to the way everyone
works: Ministers; civil servants; animal keepers and their representative organisations; vets; other
stakeholders alike. "

December 13th 2010 ~ Can the newly unveiled Cost Sharing plans take animal health policy "out of high-emotion politics and into science-based policy-making"?

Cost Sharing plans published today are described by its Chair, Rosemary Radcliffe, as able to deliver "genuine responsibility and cost sharing" but with "minimal bureaucracy and set up costs". It recommends the introduction of a Partnership Board comprising about 12 people drawn from the livestock industry and DEFRA - and based in DEFRA. It rejects the notion of an independent body for animal health and also the imposition of a disease levy. The efficiency of current expenditure should be assessed before introducing cost sharing (See Farmers Guardian article). The NFU's Peter Kendall, quoted by the Farmers Guardian thinks that the group's proposal for a Partnership Board is, as it stands,

"a missed opportunity to change the culture of the relationship between livestock keepers and the Government. We cannot see how this group can claim to be a genuine partnership between Government and livestock keepers or how it will drive significant change in this area."

CLA President William Worsley is quoted as saying that the CLA aims to give very serious consideration to the proposals

"However, there are no working models of it in government. It may well be a practicable advance on what we have, but important considerations are unclear, in particular the attitude of DEFRA and Ministers to this idea."

According to the Darlington and Stockton Times, the chair of the Responsibility and Cost Sharing Programme advisory group, Rosemary Radcliffe, expects to "sit down with the new team of ministers including farms minister Mr Paice to discuss how to proceed." She was frank about the "very substantial fears" surrounding the whole question of cost sharing.
It is cheering to read that she evidently wants to findways to restore trust between farmers and DEFRA - and that "one way to restore that trust was through a robust analysis of costs and benefits......You cannot discuss sharing responsibility or costs without numbers to have reliance on - it is basic and fundamental." Read article

May 8th 2010 ~ Cost-sharing -
Rosemary Radcliffe's comments will be of particular interest in the light of the outcome of the General Election

Government proposals will be discussed at the NBA Beef Epo 2010 in Hexham, on Wednesday, May 26. The main speaker will be Rosemary Radcliffe, chairman of the animal health responsibility and cost-sharing programme advisory group. The advisory group's recommendations will be submitted to ministers in November. See www.darlingtonandstocktontimes.co.uk

Feb 6 2010 ~ "We are very concerned about the government's determination to split health from welfare."

Madeleine Campbell, president of the British Equine Veterinary Association is quoted in Horse and Hound today:

"BEVA and the British Veterinary Association [BVA] believe this will have an adverse effect on welfare and disease containment. There will not be sufficient co-ordination between the two bodies and that will slow everything down in the case of an exotic disease outbreak."

In typical DEFRASpeak, that dismally odd mixture of patronising pomposity and jargon, the DEFRA spokesman quoted by FW spoke of the government's plans on cost-sharing as a means of "incentivising" animal-keepers to "take on their full responsibility for the management of animal health issues." The NFU has called the draft legislation "unfit for purpose". As Farmers Weekly says, this is less than a fortnight into a 12-week consultation on proposals to establish an independent body for animal health. Rob Newbery, the NFU chief adviser, is quoted as saying that the draft Bill would give farmers only a limited say in the new body, and since costs too are unclear, with the government saying only that its plans would be unveiled in a future Finance Bill, the new body itself will have no say on how funds are raised. Farmers could find themselves faced with taxes imposed by the Treasury because they own livestock.

"..The draft Bill also includes measures to reduce or withhold compensation from livestock-keepers deemed to have contributed to the circumstances that require their animal to be slaughtered. But this, too, was unworkable, Mr Newbery suggested.
"It may sound a sensible approach, but it would be impossible to set out guidance by which a government official could make a proportionate, risk-based decision on the vastly different farming systems and animal diseases."

27 January 2010 ~ "the subject is shrouded in more uncertainty than ever..."

"It was during the dark days of foot-and-mouth 2001 that the prospect of passing some of the public cost of animal disease control on to farmers was first raised by then agriculture Minister Nick Brown.
Yet nine years on, after various working groups, public consultations and seminars have grappled with how responsibility and cost sharing could work in reality, the subject is shrouded in more uncertainty than ever....
From the very early days, the emphasis has been on ensuring responsibility and cost sharing are intrinsically linked....
It was a surprised to learn the cost sharing measures would be covered at a later date under a future Treasury Bill. A 12 page Q & A on the Bill made no attempt to explain why.
It is no secret that the Treasury was unimpressed with DEFRA's botched attempt last summer at cost sharing proposals that included an unworkable compulsory insurance plan, now ditched, and other figures that spectacularly failed to add up.
Has the Treasury now decided that if it wants the job done properly it needs to take ownership itself?
... while the responsibility sharing plans are taking shape, we now know less about the cost sharing side than we did before.
It appears to be back to square one. Uncertainty still reins." Read in full.

The British Veterinary Association (BVA) has welcomed aspects of the draft Animal Health Bill but its President, Professor Bill Reilly, says:

"The draft Animal Health Bill is a mixed bag. We are delighted that, on some aspects of the new arrangements, the Government has listened to our concerns and heeded our advice. The proposed UK CVO role based in DEFRA, as distinct from the new post of England CVO ... has clarified that the UK CVO will report directly to ministers, as well as having a key coordination role in disease outbreak situations, ensuring that the veterinary voice remains at the centre of decision making. Although the make-up of the proposed Animal Health Organisation (AHO) has not been spelled out, we would expect veterinary expertise to be represented on the board and will continue to push for this....Unfortunately, we are deeply disappointed that DEFRA remains committed to splitting animal health policy and animal welfare policy. Along with many other organisations, the BVA has consistently argued that health and welfare are inextricably linked. We need to be convinced that lines of communication under the new proposals are such that welfare is not sidelined or compromised. We have not yet received those assurances..."

January 26th 2010 ~ Conservatives say there is no guarantee they would implement the Government's Responsibility and Cost Sharing plans if they come to power.

The Farmers Guardian reports.
Jim Paice has said the publication of DEFRA's draft Animal Health Bill is 'premature' since the independent joint industry and government working group chaired by the economist and government adviser, Rosemary Radcliffe, was to advise on how best to develop the independent body. Tim Farron has said the Government's decision to 'pass the buck' on to farmers by making them share the cost of animal disease outbreaks is a 'disgrace'.

January 25 2010 ~ DEFRA's draft Animal Health Bill presented today

The Bill outlines the principles of the DEFRA's Responsibility and Cost Sharing plans.
The Farmers Guardian says:

"This involves the setting up of a new 'arms length' independent body....
The plans are hugely controversial."

The Liberal Democrat Shadow DEFRA Secretary, Tim Farron is quoted

"The Government's decision to pass the buck is a disgrace. Farmers understand the need to protect public health. But in the current economic climate there can be no justification for shifting the cost to livestock farmers."

A further article in the Farmers Guardian says today that
the Bill will establish a Chief Veterinary Officer (CVO) for the UK who will be based in DEFRA but a separate CVO for England will be established alongside those in Wales and Scotland.
Hilary Benn is quoted:

"...Those running the new animal health organisation would include people with experience of the livestock industry and specialists in animal and public health, so that those making a living from animals and who are directly affected by diseases can contribute to policies and decisions about animal health."

But
Liberal Democrat Shadow DEFRA Secretary, Tim Farron, whose recent comments about farming have been praised by this website, said it was "grossly unfair" to make livestock farmers share the cost of animal disease, given that the 2007 foot-and-mouth outbreak came from Government-licensed premises.

January 2010 ~ Rosemary Radcliffe acknowledged that the draft Bill may "engender an element of alarm" among livestock producers who fear their sector could be landed with a hefty bill.

She has rejected the suggestion that the draft Bill means that decisions about the new animal health body have already been made. The Bill could go through many changes between draft and enactment.

"There is a long process of Bill scrutiny which is the reason why, if you want a new body at all, which we might by 2012, you really have to start the process now, otherwise you don't have the time to do it. So it is not a done deal at all."

The contents may well be subject to change and it is unlikely to be passed for some time.

December 3 2009 ~ Cost Sharing- no benefits except that farming takes over government costs?

At a meeting with the Junior DEFRA Minister attended by both the Tenant Farmers' Association and the National Beef Association on Monday, Jim Fitzpatrick "repeatedly defended the Government's policy on the grounds that he expected the industry to pay more for animal health policy" . "He failed to identify any benefits beyond the Government's ability to get the industry to take over some of the Government's costs for running animal health," says TFA National Chairman Greg Bliss, quoted in the Yorkshire Dales News The paper then comments on what it sees as long lived and increasing bitterness:

"Farmers view these new proposals as yet another attack on their industry by an urban-based Labour Party which has little understanding of rural needs and one is still deeply wounded by its catastrophic handling of the foot and mouth crisis eight years ago.
This bitterness is exacerbated by the fact that many believe foot and mouth came into this country because of lack of proper import controls on meat products from South America - a Government responsibility - and there was the almost laughable situation that the last outbreak of the disease came from leaking sewers at a Government-owned veterinary research centre.
Added to this resentment is the fact that DEFRA has persistently refused to create a supermarket Ombudsman to ensure that the major food retailers give the producers a fair price."

The paper talks of a
"most unhappy relationship between Government and agriculture since the industry was driven to almost total collapse in the 1930s - a neglect which took the nation to the verge of starvation in World War 11." With food security becoming more and more recognised as an urgent issue, the government would surely be better advised to rebuild trust with farmers and do everything possible to ensure food supplies at home.

November 20 2009 ~ Cost sharing - looks set to be introduced before the next General Election

"The Government is looking to develop appropriate mechanisms which will focus on behavioural change and will also help share the responsibilities and costs between Government and the farming industry for animal disease control."

Behavioural change on the part of whom was not specified.

November 18 2009 ~ Cost sharing - "we have to keep our guard up on this issue - its not gone away.."

We are very grateful to have just received the following message:

"There are some rumours/stories in the press that the Government have shelved plans for Cost Sharing for Animal Health. I'm afraid to say that this is just not the case. The confusions arises because some people expected to see the legislative bill for cost sharing in the Queens Speech later this week. However, there never was any intention to have a full blown bill on RCS in the last session of this Parliament.
The DEFRA timetable has talked about a draft bill for legislative scrutiny in late 2009 or early 2010. With a fully blown bill in the 2010 Queens Speech. It now looks as if DEFRA will publish the draft bill early in 2010 so it has definitely not gone away and we will need to look very closely at the draft bill when its published. A draft bill does give us an opportunity to have a significant input in to the legislative scrutiny. We will be able to suggest amendments and lobby MP's as it proceeds through the legislative scrutiny stages in Parliament.
So we have to keep our guard up on this issue - its not gone away!"

November 17 2009 ~ The issue to be shelved for now - "It's rather like beaching the Titanic before it reached the iceberg."

When Nicky Paull said in June that "We're asking DEFRA to go back to the drawing board on responsibility and cost sharing," she probably did not have much hope that this would happen - but it looks as though the government is shelving its unpopular plans - for now at least. Rosemary Radcliffe, the chairman of a joint industry and Government working group to work out the practicalities of so-called "Responsibility and Cost Sharing" has suggested that a Bill in the new year will outline the powers that a new independent body for animal health "might" have. It will not make clear how money would be raised from farmers.
There is little chance of such a Bill becoming law before June's General Election. The Western Morning News today quotes Ian Johnson, the South West spokesman for the National Farmers' Union.

"It's rather like beaching the Titanic before it reached the iceberg."

Although all concerned want to see a real partnership between government, industry and the veterinary profession,
"the majority of the industry don't want a new animal health body or its associated animal health tax and have pleaded with the government to abandon the project...the strength of this feeling has been made clear to DEFRA for many, many months" - as Kim Haywood of the National Beef Associationsaid in July.
Animal welfare is inextricably linked to animal health and DEFRA's proposal to separate the two met widespread resistance.
Also of deep concern was the lack of clarity in the proposals over the roles of the Chief Veterinary Officers, the Board, and Ministers. It was felt that such confusion in decision making could have disastrous consequences both for farming and for the rural economy. The position of horses, companion animals and zoos/wildlife establishments was left vague. The overriding fear was that the costs of disease control was simply being transferred to the farming industry without much thought going into the process of how actually to improve communication and disease control.
In a letter to Hilary Benn in June, the British Egg Industry Council, the British Poultry Council, the Game Farmers Association, the National Beef Association, the Royal Association of British Dairy Farmers and the Tenant Farmers Association, all united in their concern on the issue, submitted their own detailed response to DEFRA's consultation. It now looks as though the government does not want to be bothered with this issue in the run up to the election.

Oct 30 2009 ~ "we are deeply concerned about DEFRA's current plans for England.." BVA President

"In particular," said Prof Bill Reilly in his speech at the BVA North of Ireland Dinner, "the
separation of animal health from animal welfare and the lack of a clear line of command in the event
of a disease outbreak." He added that he had been appointed to the Advisory Group on responsibility and cost sharing and "as one of four
vets on the Group I shall endeavour to provide a strong voice to state our case. But I'm under no
illusion about the uphill struggle I face."
He reminded his audience that farmers in England do not readily accept the Government's arguments for the
RCS proposal, but "I believe that in the current financial climate ongoing discussion and dialogue is
needed if we are to maintain the protection that the industry, and indeed the economy, needs from
outbreaks of epizootic disease...."

September 15 2009 ~ "The DEFRA establishment is well-meaning but utterly ill-informed and disconnected from rural Britain and farming in particular."

In his interview with Farmers Weekly, Tim Farron, the Shadow DEFRA Secretary said:

"New Labour prides itself on countless "stakeholder consultations" but on the big issues - such as TB - they've got it badly wrong.
It's crazy that farmers are being dictated to by bureaucrats, especially when they're the ones who are left to pick up the pieces from the government's mistakes. If we want British farming to continue to be the best and most entrepreneurial in the world, then we must put farmers at the heart of policy decision making.
As Secretary of State I would deliberately place seconded farmers at the heart of DEFRA."

Sept 15 2009 ~ "Change is urgent and inevitable"

"Sharing Responsibilities and Costs for Animal Disease - Government Policy and the Way Forward" is an article
that was published on Saturday by the East Anglian Daily Times. It was written by Caroline Cranbrook, the Suffolk farmer. (She appears in the Country Life's September 2009 list of the 100 most powerful people in the countryside.) Her article, summing up both background and current concerns is reproduced below with the kind permission of both the EADT and the author.

Sept 14 2009 ~ Tories plan to charge farmers for the cost of a badger cull

Farmers Weekly (Sept 11):

"...A typical dairy farm is likely to face a £600 bill under proposals for a targeted cull aimed at stopping bovine TB spreading from badgers to cattle...
Tory plans for a cull are in their early stages, but proposals topped the agenda during a three-day visit by shadow farm minister Jim Paice to TB hotspot areas across south-west England this week. ... Mr Paice. "I have always said that any cull of badgers should be targeted at those setts most likely to be infected...."
Mr Paice declined to put a figure on how much individual farmers would be charged. But industry sources suggested £7.50/ha (£3/acre), meaning a £600 bill for a typical 150-cow dairy herd run across 80ha (200 acres)." Read in full
The present government is expected to spend £100m combating bovine TB this year alone.

August 30 2009 ~ "they will throw the cost back to farmers, by which time it will be too late"

NBA chairman Christopher Thomas- Everard is quoted by the Western Morning News. Read in full on the TB page.

In the light of the "Responsibility and Cost Sharing" debate,
" Unlocking
Potential" is an optimistic and emotive phrase and well chosen for the interesting
report on veterinary expertise in
food animal production by Professor Lowe, Director of the Rural Economy and Land Use (RELU)
Programme of the UK Research Councils. It is good to see many respected names among those who visited personally or who were interviewed (Annex 3) in the course of compiling the report. Chapter 6: Unlocking Potential -
Models for Change is particularly interesting. Extract:

"6.8 The relationship between government and the veterinary profession is complex and
longstanding, but has come under strain in recent years. There is an atmosphere of
mutual recrimination around the UK's patchy record in animal disease control..."

The government's compulsory register of livestock - its version of the controversial NAIS scheme in the US and Australia's loathed NLIS scheme - looks as though it is to be rushed through in spite of so many objections being made during the "consultation". On the subject of this new "central register" The Telegraph says
that horse owners are likely to be included in the new laws which

"..would also force them to take out commercial insurance policies to cover the costs of treating or slaughtering their animals in the event of an outbreak....
DEFRA documents reveal that both the registration levy and the insurance rules 'could also cover horses and their keepers.'
Registering a horse with the new animal health body would cost an estimated £10.50 for every horse, DEFRA has calculated.
There are around 650,000 horses in England and 4.3 million people ride. The equine industry is said to be worth £4 billion and to employ as many as 250,000 directly and indirectly.
Horse owners are already obliged to pay £20 for a "horse passport" which is meant to ensure that once a horse has been treated with veterinary medicines it cannot be slaughtered for human consumption."

Little by little, those whose property includes live animals are finding themselves hedged around with regulations designed to raise funds (DEFRA hopes to raise £24 million a year ) - but also to make sure ultimate power over those animals is held firmly in the hands of officialdom. This would surely have been thought unthinkable, laughable, just a few decades ago (as would some of the extraordinary amounts of money in bonuses given, for example, to "directors, senior managers, specialist and delivery managers, executive support and administration staff in the Animal Health Agency in each of the last five years.)

July 7 2009 ~ Reaction to the cost sharing proposals

On 2 April, 2009 the Farmers Guardian ran a page of industry reactions to cost sharing etc; the only positive reaction being Hilary Benn's own... The news today is that

"Jim Fitzpatrick has confirmed the establishment of a joint industry and Government working group to advise on how best to develop the new independent animal health body being introduced as part of Responsibility and Cost Sharing.
The advisory group, which will be made up of individuals from the farming industry and from Government will be chaired by Rosemary Radcliffe, who previously chaired the review into the funding of the levy boards."

The consultation ended last week - but many are saying that DEFRA had already made up its mind and never had any intention ofg listening to adverse comment from farmers themselves.

With the exception of the NFU and CLA, the main livestock sector representatives expressed opposition to both cost sharing and the establishment of a new disease control agency in the consultation that ended last week. Kim Haywood of the National Beef Association says

"The NBA has been told that Ministers are already committed..and a draft of the bill ..has already been drawn up.....even though the majority of the industry don't want a new animal health body or its associated animal health tax and have pleaded with the government to abandon the project...the strength of this feeling has been made clear to DEFRA for many, many months" (Press release)

The NBA feels that the government "should not be rushing to pass on responsibility to untried agencies or quangos."

30th June 2009 ~"We're asking DEFRA to go back to the drawing board on responsibility and cost sharing." Nicky Paull

(See
Press Release)
"BVA asks DEFRA to abandon separation of animal health from animal welfare"
Among the issues highlighted by the BVA

Animal welfare.. is inextricably linked to their health and the BVA does not support DEFRA's proposal to separate the two.

Disease control: The lack of clarity in the proposals over the roles of the Chief Veterinary Officers, the Board, and Ministers..confusion in decision making could have disastrous consequences for the farming and the rural economy.

Non-livestock animals: The implications of the new body for species including horses, companion animals and zoos/wildlife establishments are not described or considered.

The BVA says that in any new partnership arrangement the costs of diseases control must not simply be transferred to the industry.
Nicky Paull said,
"Instead of focusing on structures that confuse the process, DEFRA should concentrate on creating a real partnership between government, industry and the veterinary profession."

June 15 2009 ~ Six industry bodies have combined to express their opposition to the establishment of an independent body for animal health in England

Farmers Guardian "... in a letter to Hilary Benn....
British Egg Industry Council, the British Poultry Council, the Game Farmers Association, the National Beef Association, the Royal Association of British Dairy Farmers and the Tenant Farmers Association say they are united on the issue.
Each will be submitting their own detailed response to DEFRA's Responsibility and Cost Sharing consultation.
But they tell Mr Benn they have combined in the letter to 'leave you to be in no doubt as to the strength and unity of our concern on this issue'.
While rejecting the independent body approach, the groups said it ‘fully supports' the development of the current framework of core and stakeholder group partnerships.
"We believe this is the most effective and efficient basis for the way ahead," the letter says. ..."

May 6/7 2009 ~"We know how cavalier DEFRA is with money and it seems vital that we should have some control, since it is our money that will be spent "

www.farminguk.com quotes the chairman of the British Free Range Egg Producers Association, Tom Vesey about the cost sharing consultation launched last month. Peter Kendall's latest remarks are also quoted by www.farminguk.com He says farmers are "dismayed by DEFRA's proposals and many have little confidence in DEFRA on animal health issues" He criticises DEFRA's present management of the budget for animal health, adding,

"our view is backed by the National Audit Office" (see below) "I believe that a new independent body for animal health could deliver a more proportionate and effective animal health policy. However, it must be a genuine partnership..."

Wednesday May 6 2009 ~ DEFRA hopes to raise £24 million a year from the headage levy on pigs, cows and sheep

"...DEFRA hopes to raise £24m a year from farmers to contribute to a new animal health body, which would shave costs from the department's budget to deal with diseases such as foot-and-mouth or bluetongue.."

Peter Kendall considers this "unfair" until security at borders (for which farmers cannot possibly be responsible) is tightened. As for the insurance DEFRA thinks farmers can take out, the FT reports that insurers consider this "impractical".

The table given by Huw Irranca Davies in reply to PQ 263608 on Wednesday suggests, after a quick calculation, that such expenditure (on researching and shaping public perceptions) since DEFRA was formed in the wake of foot and mouth in 2001, has passed £4 million. Our own inability to understand exactly what all this money was spent on is evidently shared by a reader who comments:

"...2007-8: DEFRA spent over £100,000 on researching Business perceptions of DEFRA in two separate studies in 2008,
and over £28,000 on Farming Link - Qualitative newsletter evaluation. What on earth is "Farmers segmentation" which comes in at over £56,000?
2006-6: Environmental branding gets nearly £30,000 which is significantly more than Avian flu research approx. £26,000 - and Environment Direct Branding Research warrants a further approx. £57,000. Segmentation quantification costs £11,000 - what on earth is that?
2005-6 The Perceptions of DEFRA - General public tracking 2005 sounds distinctly ominous at £26,000. .."

The writer suggests that 'Perceptions of DEFRA' might have been discovered rather more cheaply - and are hardly helped by all this jargon, which should be consigned to the dustbin (along with all the other such bizarre examples of non English as coterminous stakeholder engagement).

22 April 2009 ~ NFU concerned that farmers might have to finance nine tenths of the cost of combatting an outbreak of a disease such as foot-and-mouth

The FWi reports that the NFU will fight DEFRA's responsibility and cost-sharing plans "despite conceding English livestock producers will have to accept more responsibility for animal health in future"
NFU president Peter Kendall's words to the NFU Council meeting in Leamington Spa this week are quoted:

"This is one of the most ill-thought out consultations I've ever read. The costs are based on the value of output and not disease risk so there is a risk of pitting sectors against each other..."

As Mr Kendall pointed out, the "opposition parties" have given no indication that they wouldn't introduce cost sharing measures.
"The government is looking to cut back on spending with at least £15 billion of cuts across departments already earmarked. The European Commission also expects cost sharing schemes to be in place by 2012 ..."The reaction of the National Beef Association (NBA) to the DEFRA proposals for disease cost and responsibility sharing was reported below yesterday.

21/22 April 2009 ~ National Beef Association says NO to cost and responsibility sharing because the cost to farmers would be too great

The National Beef Association has rejected DEFRA proposals for disease cost and responsibility sharing
Stackyard.com reports that the NBA :

" .. is the first organisation representing beef farmers to do so publicly and is hoping others will join with it and help to persuade government to adopt more suitable alternatives..."

The NBA proposes, as an alternative, a new drive to tackle the inefficiencies in DEFRA's current £400 million a year animal health budget. They consider that a continuation of the present core stakeholder group system would be more effective, and considerably cheaper, than DEFRA's proposed scheme.
The NBA committee considers that establishing a separate animal health board modelled on the FSA could well have better animal health results but the expense would be very great and that an unnecessary, ineffective, and inefficient tax on livestock keepers -just at the time when so many farmers are simply giving up under the pressure of costs and regulations - would be a great mistake. The NBA want an independent audit, driven by farmers, into DEFRA's management of animal health. (Thanks to the FMD news service of the University of California, Davis, for the link)

April 3 2009 ~ " This approach is disjointed,
distorted and discriminatory..."

See Feeding Britain, a report by the Smith Institute think-tank (page 74) "...Other threats come from the UK government's intention to create a new non-ministerial
department responsible for animal health policy and delivery in England... The secretary of state is proposing to pass responsibility for animal
health in England to an appointed board. This will make the decision process more
complex and administratively burdensome, but still based on the same science and
within the same constraints now imposed by the EU legislative framework. There will be
pressure for the costs involved to be passed on to England's livestock keepers through the
levies presently envisaged to pay for exotic disease outbreaks. This approach is disjointed,
distorted and discriminatory."

April 1 2009 ~ Peter Kendall: "It must be a genuine partnership between livestock farmers and the government, and must have real powers and be able to deal with the European Commission on animal health issues."

On the subject of Cost Sharing, www.thisissomerset.co.uk also quotes
South West MEP Neil Parish, Conservative chairman of the European Parliament's agriculture committee, who said, DEFRA had "a bit of a cheek" to ask farmers to contribute to disease control, given its constant dithering over bovine TB and the fact that the last major animal disease outbreak in the UK - foot-and-mouth - was caused by government failings.
"Given the misery already dished out to farmers across the country as a direct result of this Government's failures it will be a real kick in the teeth for the Government to now come to them with a bill," he said.(Recent posts on Cost Sharing)

March 31 2009 ~ BVA President urges those involved to make sure their voices are heard in the Cost Sharing consultation

Nicky Paull said today in a BVA News Release,
"The proposals described in DEFRA's consultation will have significant implications for the livestock sector including how veterinarians engage with their clients and government in managing disease.
The BVA will be examining the proposals closely and will be putting our views to government. I urge veterinary surgeons, and indeed all in the livestock sector, to get involved with the consultation and ensure that their voices are heard." (The DEFRA consultation is here. See also coverage in FWi)

March 31 2009 ~" It's the job of the government to keep out disease": Peter Kendall

"I am furious that DEFRA is still trying to get farmers to contribute to their costs when the department doesn't have a good enough handle on its own costs...."

But as Roger Breeze pointed out in his paper (when the notion of cost sharing was first put forward four years ago), if cost sharing comes with mutually accepted "performance benchmarks" it will be

"a welcome change, because when the government... set all the rules, the results were demonstrably not to anyone's liking.."

By "industry" he meant all those concerned with livestock and poultry from farm to fork. But here is the snag:

"To be a partner in a real negotiation, the industry has to know what it wants"

Officialdom has for so long insisted on being in charge that farmers with good ideas but with decreasing time, money and optimism, groan to each other about the daft rules and antiquated policies - but have not found a united voice to make explicit what is wanted. As in economics and politics generally there is a lack of vision and leadership. The exception is where people with a strong drive for safer, healthier systems can see an urgent need for change. Their voice is getting stronger and the government would be well advised to listen harder. (See also
Cost Sharing and Food Security and Transition pages)

March 31 2009 ~ "Never let a crisis go to waste. ... a chance for business to transition from an anonymous, complex system to one that is direct and transparent."

Invigorating article at Ode magazine about change from within rather than top down:

"People are tired of business as usual. The exasperation is palpable, but so is the hope that this time, we can and will do things differently..."

Rob Hopkins (Transition Culture) has just been made a Fellow of Ashoka. Its founder, Bill Drayton is quoted in the Ode article. "Social entrepreneurs are the role models, the mass disrupters and the mass recruiters of local change-makers. They are the ones who get thousands of people and thousands of communities to stand up and say together, 'Oh, that's a pretty good idea. I'm going to make that work here.' That's the spirit we need to infuse throughout society."

March 30 2009 ~ "details of proposed fund-raising mechanisms...."

Hand in hand with details about its long discussed new independent animal health body comes what Alistair Driver in the Farmers Guardian calls "a mechanism to raise funds from farmers" and yet another "consultation" is launched for the big players in agriculture
about plans for an "arms length" body to take over responsibility for animal health policy from DEFRA. "DEFRA said its proposals would 'help to reduce the risks and costs of animal disease, improve confidence in animal health policies and ensure that livestock keepers who benefit from animal disease control measures (sic) share the costs of those measures with taxpayers". As the
farmersguardian.com says

"It is likely that one of the favoured options will be a livestock keeper registration scheme that would effectively be a headage payment on each animal farmers owned."

March 30 2009 ~ dismay at plans to install "an expensive new organisation, possibly modelled on the "over-staffed and sluggish Food Standards Agency" to run animal health policies ... for which the bill is mainly funded by farmers

Last September, the NBA's Kim Haywood said she was 'dismayed' at the prospect of the registration scheme and outlined why it could cost cattle farmers as much as £30 a head. "Under current plans such a scheme would have to generate £425 million a year to fund DEFRA's unreformed Animal Health operation and then acquire a building for the proposed new body which could require a one-off payment of at least £150 million. On top of this, contingency funding to meet the expense of exotic disease outbreaks, like FMD, avian flu, bluetongue and swine fever, would have to be accumulated for research into exotic disease protection, also funded with levy proceeds too." (More)
As for "improving confidence in animal health policies" much has been lost as a result of seemingly never ending new rules and regulations, so many of which
"... are time-consuming, costly and seem to be devised by people who know little of the realities of farming in Great Britain..." as Caroline Cranbrook said recently, adding that CLA economist, Professor Allan Buckwell's view of any
' independent', new body is that it must be "non-ministerial, non-departmental agency to deal with decision-making and policy implementation for all issues of animal health and welfare... It would obviously have to have the confidence of the industry and the public, with a 50:50 industry/government balance on the board"
More

March 30 2009 ~ "the livestock production and animal product processing industry and the retail sector should all pay a share of the above costs not borne by government because all components benefit from animal agriculture - this includes auctions, retail stores and slaughter plants."

DEFRA talks of "improving confidence in animal health policies" and claims that livestock keepers "who benefit from animal disease control measures" should share the costs of those measures "with taxpayers". However, a rather more foolproof scheme has appeared several times on these pages (Industry Cost Sharing) in which "Performance Benchmarks" are a necessary component for all parties. In addition (extract):

"...The government shall ensure that sufficient laboratory capability and capacity exist to perform all diagnostic and differential diagnostic tests during and after an outbreak in a timely manner.
All components of the livestock production and animal product processing industry and the retail sector should pay a share of the above costs not borne by government because all components benefit from animal agriculture - this includes auctions, retail stores and slaughter plants. The consumers' portion is paid by government tax revenues..."

Feb 5 2009 ~ National Sheep Association says, "...good words and acceptance of recommendations is all well and fine..."

"...but if there is to be improvement those words must be turned into actions by government." Farming.uk quotes Peter Morris

"The sheep farming community still, after all this time, feels incredibly angry about what happened in 2007 and many sheep farming businesses have never fully recovered.... it is a worry that government makes such explicit references to cost and responsibility sharing in their responses to the Anderson recommendations. What will not be acceptable is for government to feel it has fulfilled its obligations to improve by simply passing on costs .."

".. the best way to encourage farmers to vaccinate their stock against BTV and anything else that crawls out of the woodwork in the next few years is to offer them a hefty discount the more proactive they are.."

"With all the talk of compulsory registration schemes and possible headage payments so that farmers can help pay for outbreaks of disease, I would like to feel there will be some kind of discounting system in place. Surely the best way to encourage farmers to vaccinate their stock against BTV and anything else that crawls out of the woodwork in the next few years is to offer them a hefty discount the more proactive they are in managing their own animals' health. Those who belong to the various elite Health Schemes and the Scrapie Monitoring Scheme should also have discounts as should anyone who has an agreed and audited Herd Health Plan drawn up with their vet.
If a discounted system is not part of the package then this would be a tremendous opportunity wasted. I have no idea how to go about suggesting this but as always, talking to Warmwell seems to get the idea hoisted up above the parapet!"
Lesley Prior in Devon

Hansard, yesterday. This was the answer given when Jane Kennedy was asked by Bill Wiggen what plans DEFRA has ".. to establish an arm's length body responsible for animal health." It seems that the Minister did not feel like sharing her thoughts on this matter just yet. The tireless MP from Leominster then asked the Secretary of State (Hansard) what plans DEFRA has

" to require livestock keepers to enter into a compulsory registration scheme"

He asked for a statement. What he got was: "A compulsory annual fee based registration scheme of livestock keepers is being considered as part of the wider responsibility and cost sharing agenda for animal health. The purpose of the scheme would be to raise contributions from industry towards the control and eradications of exotic diseases." She then repeated, "We plan to consult on specific proposals for implementing responsibility and cost sharing for animal health shortly." (The verb "consider" has different meanings at different times for DEFRA, it seems. For years "consider the use of emergency vaccination" has meant "it is unlikely to happen". Here, the compulsory annual fee is being "considered" too; it would be cheering to think a consultation could make it anything other than a foregone conclusion.)

February 4 2009 ~" well and truly bushwhacked in a carefully planned ambush" Kim Haywood

An article on www.farminguk.com reveals that what was a Government proposal that farmers provide match funding for all the disease surveillance and awareness work seems now to be already included in the government's current budget.

"..The shock move... is contained in DEFRA's response to the Anderson review....
Describing the development as "a stiletto slipped between the ribs of an unsuspecting industry" National Beef Association director, Kim Haywood, says government determination to curb its disease control costs by imposing a headage based levy is now obvious to all."

The article goes on to say that any future discussion on so-called "RCS" (Responsibility and Cost Sharing) will now have focus on how to make cost sharing affordable and ensuring that any money farmers contribute is spent effectively. Which individuals are to contribute is not yet worked out. Kim Haywood is quoted again:
"The text of DEFRA's response to the Anderson Review is already before Parliament so there is no chance of the offending paragraphs being held back for re-consideration. This means an uninformed livestock industry has been well and truly bushwhacked in a carefully planned ambush."Once again,
farmers, particularly those in small family farms, seem to be without a voice to ask for answers. Even the best farming unions seem powerless. There is no mention, for example, of the cost of FMD vaccine nor how much
farmers would have to pay for disease outbreaks and surveillance. Read article and see pdf file of government response to the Anderson Report and recommendations.

As we mentioned on September 9, DEFRA is considering establishing another new body, responsible for animal health but not "animal welfare" which is to remain DEFRA's - either as a non-ministerial department or a non-departmental public body. The new body will be responsible for determining policy but the old SVS, now "Animal Health", the Veterinary Laboratories Agency and the Veterinary Medicines Directorate will, as at present, be responsible for delivering the policy.
DEFRA's proposals include the creation of an additional revenue stream for animal health through compulsory registration of livestock keepers.
The BVA's
editorial comment this week (December 13, 2008) concerns DEFRA's presentation at the BVA's Council meeting in London last week on its "consultation document on sharing the costs and responsibilities of animal health". The BVA is not very happy. Extract:

"...there was some consternation... at the suggestion that animal health and welfare should be separated - not surprisingly, as the two are interdependent.
Council was also concerned about the consequences of policy development and policy delivery moving further apart, ....who would take control in the event of a serious disease outbreak and about how things would work in the devolved administrations, disease being no respecter of national boundaries.
Again, BVA has previously argued that, if a levy system were to be pursued, it should apply all along the food chain, including the retail end and include incentives to reward good practice. Sadly, neither of these aspects seems to feature in the proposals currently being considered by DEFRA."

November 6 2008 ~ Cost-sharing ".... they have taken their
bat home because they do not think you have played fair with them on bovine
TB.."

EFRA Committee oral evidence is always interesting (even if only to be staggered by the extraordinary English employed by some DEFRA officials) On 29th October, Helen Ghosh was asked, among many other things, about cost sharing. As Paddy Tipping's question (85) acknowledged, the NFU represents only some of those who may find themselves paying an unaccountable piper. As to the NFU's having taken their bat home, Dame Helen said, "they are still playing with us on an awful lot of other
fields, actually, yes..." She also, with rather less than perfect clarity, informed the EFRA Committee,

" we have never intended to have a cost-sharing bill in
this session. We had one consultation on the cost-sharing proposals and the idea
of the creation of a joint body to bring that to life. We are currently looking
at the policy and talking to stakeholders and will come forward with a more
detailed proposition for consultation, and then we would move to a draft bill.
So a draft bill would not happen until - I am getting my sessions muddled up. It
would be, I think, the next session, not the one that is about to start but
2009-10 and then subject to discussions on that a full bill thereafter. So
setting up the body is something on which we have had preliminary consultation,
we will have some more, and then we will move to a draft bill."

November 4 2008 ~ "The NFU has confirmed that it is not engaged in any discussions with DEFRA on livestock disease cost and responsibility sharing"

FWi "This follows an announcement yesterday (3 November) that the NFU, along with other livestock organisations, will help set up a new Bovine TB Eradication Group." (see TB page latest) A Parliamentary Question from Roger Williams yesterday: To ask the Secretary of State for Environment, Food and Rural Affairs what assessment he has made of the effect of cost and responsibility sharing for animal disease on the effectiveness and profitability of British farming" received this from Jane Kennedy

"The Government intend to consult on specific proposals for sharing responsibilities and costs for animal health in England later this year. These proposals will be fully costed and accompanied by an initial impact assessment."

August 14 2008 ~ farmers to pay a headage fee in return for "possibly" an independent body on Animal Health policy

It looks as though livestock farmers in England are going to be forced to pay a fee for every animal they produce. The plan is part of the government's cost sharing scheme about which we have commented several times.
The money collected would fund a new animal health body. There are apparently two options - the first is to create a department like the Food Standards Agency, considered to be independent and without a Minister.
The other is for a public body, "along the lines of the Agriculture and Horticulture Development Board" funded through DEFRA and answerable to DEFRA Ministers. Although the consultation will discuss

"how much independence it will be granted from Ministers... and how it responds to major disease outbreaks"

the "newness" and "independence" may not satisfy the call for an independent body to take on the future decision making for animal health made last month in an eight-point statement of agreement by an industry stakeholder group. A DEFRA spokesman quoted in the
Farmers Guardian article made it clear that the new body would not be built from scratch but instead be made up from Animal Health, (i.e.the SVS) and parts of DEFRA itself. The reins of control, once grasped, are never lightly given up - but a strand of accountability, such as suggested here in Dr Roger Breeze's paper, Industry Cost Sharing, must surely be an essential part of any scheme..

July 23 2008 ~ Non-participation in cost-sharing. Non participation on "TB Partnership". New call for a truly independent body on Animal Health matters

An indication - if any were needed- of how far the gulf has widened between farmers and the government can be seen in this NFU release which reports that an "... industry stakeholder group has put its name to an eight-point statement of agreement following the non-decision announced by the Secretary of State, Hilary Benn, on dealing with bTB......Included in the eight points is a call for an independent body to take on the future decision making for animal health; a commitment of non-participation in the TB Partnership Group as announced by the Secretary of State; and an industry policy of non-participation in discussions on cost sharing and responsibility on animal health and welfare issues.." Click here for the 8 points of the industry wide stakeholder group - while today's EFRA report's main points can be seen here

June 21 2008 ~ DEFRA won't help towards Surrey's £250,000 FMD bill.

The BBC reports that Surrey County Council said it was disappointed not to be reimbursed for the hard work put in to stop the spread of the disease. DEFRA retorted that local authorities already had funding for emergencies - forgetting perhaps that six months ago, government funding to local authorities for animal health and welfare was cut by about 12%.
DEFRA:

"... Where local authorities act during an emergency, they do so on their own responsibility rather than on the instructions of DEFRA."

So there we are. It all comes down to responsibility. The leak from Pirbright was not the government's responsibility, urgent funding for Pirbright (see below) was not their responsibility and the huge bill caused by Pirbright's poor state was not the government's responsibility. But what was the government's responsibility was making all the decisions, refusing to vaccinate and turning its deaf ear to expert advice. For the government, "responsibility" means that the costs of their own policies and muddled responses are met by others. Despite the endless stream of regulations making farmers and managers ever more accountable, DEFRA and the government are not, it seems, ever to be held responsible themselves. (This paper shows what would be a saner approach to industry cost sharing and governmental responsibility.)

June 2 2008 ~ "...regular contact with stakeholders, and being as open as
possible about current and future policy-making, has contributed to creating a climate of trust" CVO report 2007 (page 21)

The pdf file Animal Health 2007
The Report of the Chief Veterinary Officer has quietly arrived on the DEFRA website today.
Topics covered in the 2007 report include bovine TB ("DEFRA aims to work in partnership with interested
organisations to bring about a sustainable improvement in control of the disease by 2015...") the outbreaks of Foot and Mouth Disease ("A great deal has been done since 2001 on building relationships with a wide range of
non-governmental organisations...".) Avian Flu ("DEFRA's contingency plan was implemented effectively to control the
outbreak...") and Bluetongue ("..there is a real concern that the
disease will become more widespread and enter Wales..") and progress on the UK's Responsibility and Cost Sharing Programme ("Significant progress has been made in 2007 to take the responsibility and cost sharing agenda
forward...") "a challenging year due to the combined impact of Avian
Influenza, Bluetongue and Foot and Mouth Disease," says the Foreward, signed by Fred Landeg. In the sole reference to her in the report, he expresses gratitude to
" in particular, our former Chief Veterinary Officer,
Dr Debby Reynolds." (Link to pdf report)

May 28 2008 ~ Surrey County Council will prosecute neither IAH Pirbright nor Merial over FMD leak last August

The Telegraph reported this afternoon that Surrey CC has "called for tougher measures which would ensure that where two laboratories shared facilities, one should have ultimate responsibility and accountability for the site....."So once again, as in Albert and the Lion, "no one was really to blame..." Unless, of course, one remembers the pleas from Pirbright to DEFRA and to the Treasury that were ignored. They were alerted to the desperate lack of funding long before the virus leak - as the memorandum at the end of the Science and Technology
Committee's 4th report volume 2) makes clear. Although the Department was able to find a total of £418 million
to pay the EU fine for the RPA delays, in 2006 it could not find the resources to keep its own dangerous house in order when it mattered - and now washes its hands of the financial fallout from the leaked virus. Interestingly, the Welsh NFU president, Dai Davies, is quoted today (:www.dailypost.co.uk)

"The whole issue of responsibility and cost sharing must be viewed against the government's continued refusal to accept their responsibility for the release of the FMD virus from the Pirbright facility."

Country Land & Business Association deputy president William Worsley is quoted on farming uk: "This is extremely worrying .... will set a dangerous precedent for similar situations caused by the negligence of public bodies. It suggests public bodies are not subject to the same level of accountability as everyone else. This is despite a seemingly endless stream of regulations affecting rural businesses that makes managers ever more accountable for their actions."

Animal disease needs planned spending - and lots of it, unfortunately. The campaign against Bluetongue, for example - a disease of which the majority of the population has never heard but one which could wipe out our livestock farming - is in desperate and urgent need of informed and properly funded organisation. At a time when the global economic situation is fragile we really must reconsider the local availability of safe food and cherish our livestock farmers. Demanding that sheep farmers, hit by a succession of hardships, now pour money into a fund that has no safeguards is suicidally ill thought out. (Whereas this paper on cost sharing suggests an acceptable way forward.) Those holding the Treasury purse strings must surely face some stark realities. We have every sympathy for those who must try to make sense of the muddle while still protecting the country from harm.

January 4th 2008 ~ "Vigilance" plea repeated yet again

Fred Landeg's repeated mantra of "vigilance" in his plea to farmers to "learn the lessons of 2007" might be considered somewhat worse than tactless in the circumstances when so many farmers are reeling from the Pirbright virus leak and the disastrously far-reaching effects of the attempts to cope with it. A campaign to push for full compensation may rumble on for months. Meanwhile, Hilary Benn's speech at the Oxford Farming Conference, according to the Farmers Guardian, "contained little new in terms of ideas or policy." It did, however, show a government pressing on against all the odds to insist on cost sharing.

(Industry Cost Sharing - the wisest plan on sharing the cost of animal disease control we have read: a paper by Dr Roger Breeze. Click here) Paper by Dr. Roger Breeze,
CEO, Centaur Science Group (formerly, Associate Administrator, United States Department of Agriculture, Agricultural Research Service), Washington DC.

Industry Cost Sharing

In the US, the Golden Rule is that he who has the gold
makes the rules. That the British government is now looking to the livestock
industry to share the costs of epidemic disease control is a welcome change,
because when the government had all the gold and set all the rules, the results
were demonstrably not to anyone's liking. Cost sharing offers industry a chance
to sit at the table as a partner to make sure that when it pays what is asked,
it gets what is promised. In this
context, I use "industry" to mean those concerned with the raising, processing
and sale of livestock and poultry from farm to fork in the UK, including all zoo
and commercial animals and birds (from which commerce or profit is derived)
regardless of species. There are other private sector industries that I will
identify later in the narrative.

To be a partner in a real
negotiation, the industry has to know what it wants so that proposals from the
government can be assessed in terms of how well they advance or retard what
industry wants to see as the outcomes. Industry cannot negotiate meaningfully if
its "negotiation" comments are only responses to proposals and goals of the
government.

The following comments are
directed at all foreign animal and poultry disease emergencies but particularly
for foot and mouth - one cannot detail all possibilities here.

Industry desires might be as
follows:

1.FMD does not occur in the UK or the
EU.

2.The only way FMD virus can become a
livestock problem in the UK is if someone accidentally or deliberately brings
the virus, live infected animals or infected animal products into the
UK.

3.The industry has no powers to
prevent accidental or deliberate FMD introduction - this is an essentially
governmental function. The industry recognizes that a portion of the costs of
keeping FMD and other infections out of the UK should be borne by those passing
across the country's borders or importing animals or goods that might carry
these infections.

i.Plans
should be developed for effective screening of persons, conveyances (cars,
trucks, boats, planes) and goods of all kinds arriving in the UK to ensure that
illegal imports of animals and animal products that might carry foreign
pathogens of concern are detected.

ii.Performance Benchmarks should be established - what proportions of
passengers, conveyances and goods will be examined, how they will be examined
and how results will be reported. When possible, robotic automated devices
should be employed to screen the maximum numbers of potential
targets.

iii.Industry accepts that it is not possible to examine all travelers, goods
or conveyances and will agree with government what an acceptable fraction should
be. Later, there might be redirection of inspection resources based upon risk
assessment and experience. A case can be made to inspect a greater proportion of
travelers, containers and goods coming from countries in which FMD and other
diseases of concern are known to be present than from disease-free countries,
thereby encouraging countries to eradicate disease within their
borders.

iv.A fee
should be assessed on all travelers, conveyances, shipping containers and goods
entering UK to pay for an agreed share of the increased costs of inspection.
This fee would be greater for conveyances carrying live animals or animal
products and for imports of live animals and animal products - but inspection
should not be restricted only to these since the declared manifest might be
incorrect. Reduced fees might apply to those meeting higher standards of
validation as to the nature of the import and country of origin. ALL sector components should contribute
- the shipping companies as well as the shipper - to ensure that all are vested
in the outcome. There should be real and significant penalties on the boat,
truck or airline industry members found to be carrying illegal imports to
discourage illegal imports at the point of loading in a foreign
country.

v.On a
non-disclosure basis, the government should make available to industry
representatives the records on how well Performance Benchmarks are being met -
the government should have the necessary resources to meet these benchmarks from
tax revenues and user fees and be prepared to demonstrate that it is meeting its
Performance promises.

vi.Laws
and regulations on penalties for failing to comply with importation requirements
should be reviewed to ensure that penalties are commensurate with the likely
degree of economic consequence.

vii.Through differential fees, the government should encourage adoption of
importation practices that minimize fraud and maximize effective inspection,
such as source validation, unalterable product seals, electronically verifiable
certificates of origin, and lifetime tracking of the imported products in ways
that can be validated in real time by the customs inspector at the point of
importation.

viii.The
purpose of the above program component is to ensure that all those engaged in
entering the UK, with and without products or animals that might carry
infection, contribute towards the costs of an effective program with measurable
impact on preventing illegal importations.

4.Government has chosen to retain all
powers to diagnose FMD and to respond to an introduction by vaccination and
other health interventions and by release of vaccine to livestock owners. The
industry is willing to share the costs of an agreed and effective diagnostic and
response system in which government meets agreed Performance Benchmarks that
will limit industry losses should FMD occur. By "livestock" below I also intend
zoo, game and other non-farm animals and birds.

a.Early reporting of suspicious cases
is critical to limiting any subsequent epidemic. Through education and training,
the government should ensure that livestock owners and those employed in the
industry know what to look out for and how to report suspicious cases. An
inducement scheme might be adopted to encourage reporting. This component should
have Performance Benchmarks.

b.Within 6 hours of notification by a
veterinary surgeon of a suspicious case, government should have made a
definitive detection of the foreign animal disease by transporting samples to
Pirbright or by examining samples in regional laboratories or on the farm. This
component should have Performance Benchmarks.

c.In cooperation with the livestock
industry and the Royal College of Veterinary Surgeons, the government shall have
in place an emergency communications capability to inform directly all UK livestock owners and veterinary
surgeons or a defined subset of them immediately (within 1 hour) after a
definitive diagnosis. This communication system might be by telephone or other
electronic means. This component should have Performance
Benchmarks.

d.Through education and training, the
government shall ensure that all livestock owners and veterinary surgeons know
what preventative measures they should employ under their farming circumstances when
disease is diagnosed. This component should have Performance Benchmarks.

e.Within 24 hours, government should
have determined the strain or subtype of the pathogen and ordered the production
of the most efficacious vaccine from stockpiled antigens. This component should
have Performance Benchmarks.

f.The government will maintain a
stockpile of vaccines (in the form of frozen antigen of indefinite shelf life)
to protect UK livestock against all strains of the pathogen circulating in the
world. The numbers of doses of each vaccine may not be the same as the total
number of susceptible animals or birds but the government shall fully compensate
owners for whom vaccine is not available in the event of an
outbreak.

g.The government will have a plan and
capability to deliver sufficient vaccine for all susceptible livestock to their
owners at pre-determined distribution points starting 72 hours after definitive
diagnosis and being complete by 144 to 168 hours. This component should have
Performance Benchmarks.

h.The government shall ensure that
sufficient laboratory capability and capacity exist to perform all diagnostic
and differential diagnostic tests during and after an outbreak in a timely
manner.

i.All components of the livestock
production and animal product processing industry and the retail sector should
pay a share of the above costs not borne by government because all components
benefit from animal agriculture - this includes auctions, retail stores and
slaughter plants. The consumers' portion is paid by government tax
revenues.

j.The purpose of the above program
component is to ensure that all those benefiting from production, processing or
sale of animals and animal products of UK origin and those similarly benefiting
from imported animals or animal products contribute towards the costs of an
effective program for earliest detection and most rapid effective response to
foreign animal and poultry disease threats and are actively engaged in such a
program should disease occur.

5.When a disease outbreak occurs
during a period in which the government is not meeting its Performance
Benchmarks for importation security, the industry shall not have to pay its
share of disease control and compensation costs stemming from failure on the
government's part.

6.When a disease outbreak occurs
during a period in which the government is not meeting its Performance
Benchmarks for diagnosis, vaccine deployment and preparedness, the industry
shall not have to pay its share of disease control and compensation costs
stemming from failure on the government's part.

7.Livestock owners will be compensated
for the value of stock slaughtered in the period before vaccination has occurred
and disease control measures are fully implemented - this might be as long as
two weeks after definitive diagnosis. The first owner to report a suspicious
case that proves to be an infection of concern shall be compensated at four
times the value of the stock; those subsequently reporting suspicious cases that
prove positive within the first two weeks after a definitive diagnosis shall be
compensated at twice the value of the stock. Owners of stock deemed to be
infected more than two weeks after definitive diagnosis shall not be compensated
from government funds, although insurance against such an eventuality shall be
offered in advance. This scheme is intended to promote industry-wide vigilance
and immediate diligent attention and response after disease is diagnosed.

8.With all Performance Benchmarks met,
by government and industry, the goal is to snuff out an outbreak in two weeks
after diagnosis by active commitment of all sections of the industry and related
industries.

9.The issue of who should pay what in
the event of deliberate introduction of disease is difficult. Deliberate
introduction will be either a crime or a terrorist attack - deterring and
responding to either of these are inherently governmental functions.I have argued that changing the way
government responds to FMD and other foreign infections can reduce or remove the
terrorist threat since it is the drama and visual theater of mass slaughter and
destruction that the terrorists seek to have shown on al Jazeera and BBC World
News. This is why I assume vaccination above, not mass slaughter. I am not sure
of UK law on insurance against terrorist attack - if terrorism causes damage,
does the liability fall to government not the insurer? Who paid for the physical
damage to the London Underground? Was it insurance or the government? Seems like
a similar principle would hold for deliberate disease
attack.

Prevention and control of animal disease are of
incalculable importance to the livestock industry and to the health and
well-being of the human population. Some diseases, such as foot and mouth, only
affect livestock. Others, such as bovine TB and avian flu, are a real threat to
human health. It is in the interests of everyone that animal diseases should be
prevented and controlled as scientifically, efficiently, economically and
humanely as possible. At present this is not happening. The devastating spread
of bovine TB is a dreadful example of the failure of existing policies,
resulting in huge costs to the industry, to individuals, to animals, to the
taxpayer and to the reputation of British livestock.

The regulatory framework of animal health and
welfare remains excessively complex, bureaucratic and expensive. At present, 14
governmental bodies are involved, some with overlapping responsibilities.
Channels of communication are often ill-defined, as are lines of responsibility.
Links between scientific research and policy are particularly opaque. And the
costs are enormous. Sometimes this has been the consequence of ill-conceived
government policies, such as the deplorable, unscientific, impractical
contiguous cull of livestock in the first foot and mouth epidemic. At the same
time, the EU requires a mandatory framework for sharing responsibilities and
costs to be in place in all member states by 2010. Meanwhile, DEFRA's budget is
continually being reduced.

So, for all these reasons, DEFRA plans to share
responsibility and costs of animal disease with the livestock industry by
introducing new arrangements, though it intends to keep animal welfare separate
as part of DEFRA. The new framework will involve the whole livestock industry -
even those who rear game-birds - but possibly not horse owners.

Change is urgent and inevitable. Following
extensive consultations, DEFRA has put forward a variety of proposals as to how
sharing responsibility and costs will work. The one supported by the CLA, the
NFU and the British Veterinary Association is that a new body, a Non-Ministerial
Department (similar to the Food Standards Agency), would be established,
governed by an animal health board and staffed by personnel transferred
from DEFRA. A joint advisory working group on the proposals is being set
up but, although it has a chair (the economist Rosemary Radcliffe), to date it
has no members. Government expects the total cost to be £44 million a year, with
£22 million coming from the industry. Start-up costs are estimated at £12
million and running costs at £2 million a year.

The CLA, NFU and BVA all agree that we need a new
approach to animal health and welfare (which should remain together) and that
this should be based on a genuine partnership with DEFRA. This is crucial.
Although in principle they support the proposal, there are concerns about the
new board's powers and independence regarding policy. There are also other
concerns relating to membership of the board, to staffing, to cost and to a
number of other outstanding issues, such as animal welfare.

As regards sharing responsibility for animal
health and welfare, the CLA is very clear that the new board must be separated
from ministerial politics. It should be truly independent of ministerial control
and have real responsibility, not only for animal health but also for animal
welfare. The two cannot be separated and both must be taken out of politics and
be given stronger links to science. Logically, the existing Animal Health Agency
and the Farm Welfare Council should become the executive agencies of the new
body. Prevention and control of exotic diseases, particularly the zoonoses
(those which infect people as well as animals) should be government-funded as
they provide a public good. The new body should be empowered to simplify and
reduce the regulatory framework. It should also be allowed to operate at EU
level and be able to advise ministers when they negotiate in Europe.

An unresolved problem is the lack of uniformity
across the United Kingdom. The devolved administrations in Scotland, Wales and
Northern Ireland will operate differently. This will have serious consequences.
Disease does not recognise frontiers. If different systems and standards are
introduced in different UK countries, this will inevitably distort competition,
making livestock farming and disease control more difficult. The livestock
industry and its markets, abattoirs, meat plants and the supermarkets are all
closely interconnected and operate freely across the United Kingdom. Introducing
new artificial boundaries relating to disease would inevitably distort the
industry, making it uncompetitive and more difficult to operate.

The CLA has concerns about the membership of the
new board. DEFRA suggests members should be appointed according to Nolan
rules. This is fine for DEFRA's own appointees but if the industry is paying for
50% of the costs, then it should be allowed to choose the members who represent
it from its own sectors - beef, sheep, pigs and poultry. I suggest that
smallholders and the rare breeds should also be represented, as should the
private sector vets and probably LACORS (Local Authorities Regulatory Services),
which has an important regulatory role. The Chief Veterinary Officer, together
with DEFRA's chief scientist should certainly have seats on the board. It is
essential that strategy and good practice are based on the best up-to-date
science and on the practical, local knowledge that the livestock sectors and
their vets can provide. This should go some way to improving and making more
transparent vertical and horizontal communication, the lack of which has been a
constant criticism in the past.

Staffing needs to be looked at carefully. DEFRA
employees should not automatically be transferred to the new body. Many will
have unique knowledge and expertise. Even so, if we are starting afresh, then
individuals should be invited to apply for jobs which have terms and conditions
similar to private industry.

The industry should certainly help fund the new
organisation. However, the CLA is unhappy with DEFRA's proposals. Trust first
needs to be rebuilt between government and livestock farmers, many of whose
businesses are being crippled by government's unwillingness to take measure to
control bTB. Imposing a new cost structure before setting up the new independent
body would completely undermine confidence in it. The CLA is also critical of
DEFRA's calculations in its Impact Assessment, as is the National Audit Office,
which has stated that ‘the Department does not havesufficiently
robust financial or performance information on controlling diseases to assess
routinely the costs and benefits of intervention, and to underpin a transparent
and equitable cost-sharing scheme'.

It is unclear how DEFRA has calculated the cost of
£44 million a year. It has also under-estimated the costs already borne by the
industry. We need better and more transparent cost analysis and a new
consultation on the true costs, disease by disease, sector by sector, before we
agree to pay our share. The £12 million set-up and £2 million a year running
costs seem excessive and need to be detailed in full and reduced. The example of
the Meat Hygiene Service (the enforcement agency of the Food Standards Agency)
is not encouraging. In 1995, the total cost of the MHS was £29 million but by
2007 this had gone up to £94 million, an increase of over 320%. It is essential
that costs are tightly controlled by the new animal health body, otherwise it
will be the end of livestock farming. Insurance has also been suggested by
DEFRA, but it is not possible to insure against exotic disease, while commercial
insurers say they are unable to assess the risks and at present are unlikely to
provide the sort of cover suggested by DEFRA.

DEFRA's responsibility and cost sharing initiative
provides a unique opportunity for the livestock industry, the vets, the
scientists, the regulators and DEFRA itself to revolutionise and make more
efficient the prevention and control of animal disease. However, we must end up
with a better, more science-based, practical, streamlined affordable system
which is less bureaucratic, with costs properly evaluated, reduced and
controlled. There has to be a genuine partnership. And this can only happen if
the new Non-Ministerial Department is truly independent, responsible for both
animal health and welfare and with genuine powers of decision. We cannot go on
as we are but we have to get it right.